Unsorted FBI Documents

AO 91 (Rev. 1 1/82)

CRIMINAL COMP

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA

PAUL ANTHONY CIANCIA

CENTRAL DIS

DOCKET NO.

$•- VENTRAL DISTRICT OF CALIFORNIA

MAGISTRATE’S CASE NO.

Complaint for violation of Title 18, United States Code, Sections 1114 and 37

NAME OF MAGISTRATE JUDGE

HONORABLE JACQUELINE CHOOLJIAN

LOCATION

UNITED STATES T , ' .

MAGISTRATE JUDGE Los Angeles ’ Callforma

DATE OF OFFENSE

11/1/13

PLACE OF OFFENSE

Los Angeles County

ADDRESS OF ACCUSED (IF KNOWN)

COMPLAINANT’S STATEMENT OF FACTS CONSTITUTING THE OFFENSE OR VIOLATION:

[18U.S.C. § 1114]

On or about November 1, 2013, in Los Angeles County, within the Central District of California, defendant
PAUL ANTHONY CIANCIA killed and attempted to kill officers and employees of the United States and of an
agency in the executive branch of the United States government, namely, employees of the Transportation
Security Administration, while such officers and employees were engaged in and on account of the performance
of official duties.

[18U.S.C. §37]

On or about November 1, 2013, in Los Angeles County, within the Central District of California, defendant
PAUL ANTHONY CIANCIA unlawfully and intentionally, using a firearm, performed an act of violence at
Los Angeles International Airport, an airport serving international civil aviation, that caused and was likely to
cause serious bodily injury and death.

BASIS OF COMPLAINANT’S CHARGE AGAINST THE ACCUSED:

(See attached affidavit which is incorporated as part of this Complaint)

MATERIAL WITNESSES IN RELATION TO THIS CHARGE: N/A

SIGNATURE OF COMPLAINANT /

Being duly sworn, I declare that the KHOORYARTAN X<

foregoing is true and correct to the best — — /- — j

of my knowledge. official title

Special Agent - Federal Bureau of Investigation

Sworn to before me and subscribed in my presence,

SIGNATURE OF MAGISTRATE JUDGE (1)

DATE

November 2, 2013

(I) See Federal Rules of Criminal Procedure 3 and 54

AUSA Melissa Mills ext. 0627 REC: Detention

AFFIDAVIT

I, Stephen J. Khoobyarian, being duly sworn, hereby depose and
state the following:

1. I am a Special Agent of the Federal Bureau of Investigation
(FBI), and I have been so employed for over eight years. I am
currently assigned to the FBI's Long Beach Residence Agency Joint
Terrorism Task Force ( JTTF) , where I investigate international
terrorism, domestic terrorism, and other violations of Federal law,
including those that occur within the airport environment and on
board aircraft.

2. This affidavit is in support of a complaint charging PAUL
ANTHONY CIANCIA ("CIANCIA") with violating Title 18, United States
Code, Section 1114: Murder of a Federal Officer; and Title 18, United
States Code, Section 37: Violence at International Airports; on
November 1, 2013, at the Los Angeles International Airport (“LAX”) ,
located in Los Angeles, California, in the Central District of
California .

3. The facts set forth in this affidavit are based on my
personal observations, my training and experience, and information
obtained from other law enforcement officers and witnesses. This
affidavit is intended to show that there is probable cause for the
requested complaint and does not purport to set forth all of my
knowledge or investigation into this matter.

4. Title 18, United States Code, Section 1114 prohibits, in
pertinent part, “kill[ing] . . . any officer or employee of the United

States or of any agency in any branch of the United States Government
. . . while such officer or employee is engaged in or on account

of the performance of official duties.”

5. Title 18, United States Code, Section 37 prohibits, in
pertinent part, the following conduct: “unlawfully and
intentionally, using any device, substance, or weapon — performfing]
an act of violence at an airport serving international civil aviation
that causes or is likely to cause serious bodily injury ... or
death . ”

6. According to eyewitnesses and video surveillance footage,
on November 1, 2013, at approximately 9:20 a.m., CIANCIA entered
Terminal 3 at LAX and approached the Transportation Security
Administration ("TSA") checkpoint. CIANCIA pulled a Smith & Wesson
.223 caliber M&P-15 assault rifle out of his bag and fired multiple
rounds at point-blank range at a TSA officer who was then on duty
and in uniform, wounding the officer. CIANCIA began to walk up an
escalator, looked back at the wounded officer, who in video appeared
to move, and returned to shoot the wounded officer again. The TSA
officer was fatally wounded. CIANCIA then fired his weapon on at
least two other uniformed, on-duty TSA employees and one civilian
passenger, all of whom sustained gunshot wounds . CIANCIA was pursued
and shot by a sergeant and an officer of the Los Angeles Airport
Police. Multiple terminals were evacuated and air traffic into and
out of LAX was halted, and air travel across the globe was disrupted.

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7. I learned from other law enforcement agents that from a
bag that CIANCIA carried with him at the scene, agents recovered
a handwritten letter, signed by CIANCIA, stating that CIANCIA had
"made the conscious decision to try to kill" multiple TSA employees.
Addressing TSA employees, the letter stated that CIANCIA wanted to
"instill fear in your traitorous minds." CIANCIA' s possessions on
the scene also included five magazine clips of ammunition for his
assault rifle.

8. From my training and experience, I know that LAX is an
airport serving international civil aviation. TSA is a federal
agency within the Department of Homeland Security, in the executive
branch of the federal government, charged with securing the airports
of the United States and screening all commercial airline passengers
and baggage. TSA officers are employees of the United States
government .

Ill

III

III

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9. Based on the foregoing, I believe that there is probable
cause to believe that PAUL ANTHONY CIANCIA violated Title 18, United
States Code, Section 1114: Murder of a Federal Officer; and Title
18, United States Code, Section 37: Violence at International
Airports .

/4 /

STEPHEN J. 'KHOOB^ARIAN
Special Agent-FBI

Sworn and subscribed to before
me this 2nd day of November, 2013.

UNITED STATES MAGISTRATE JUDGE

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